To begin, I fully and…

To begin, I fully and completely reject the amalgamation or consolidation of the 36 Conservation Authorities. All issues that may arise can be addressed within the current framework that is set up by the Conservation Authorities Act and with 36 Conservation Authorities.

Ontario is losing greenspace at an alarming rate. Between 2016 and 2021, the province lost over 580,000 acres of farmland, with land continuing to be converted at roughly 319 acres per day. With this ongoing loss, Conservation Authorities play a critical role in protecting wetlands, floodplains, and open space, providing essential services such as flood mitigation, erosion control, and climate resilience.

The Government of Ontario funds, on average, only 1% - 8% of each Conservation Authority’s budget (the top end includes funds and grants) with on average 53% of each budget funded by municipal levies, 35% funded by self-generated revenue, and 4% percent funded by federal grants or contracts. At 53% of the funding, municipalities should have the say on if they are unhappy with Conservation Authorities, many of these municipalities and their councillors are speaking out against this decision. It makes very little sense to overhaul such a long standing practice in Ontario without speaking with Municipalities and removing municipalities entirely.

This change will dilute local accountability and municipal partnership, contrary to the principle that decisions are best made closest to the communities they affect. Municipalities have governed their respective conservation authorities for decades, tailoring programs and services to local watershed needs, maintaining accountable service standards, and ensuring fair and predictable costs for ratepayers

Flooding is expensive, disruptive, and time-consuming, with costs borne by municipalities and local taxpayers through emergency response, infrastructure repair, and long-term recovery. Strong, locally informed watershed management is far more effective and less costly than reacting after damage occurs. No one wants these crises to happen to them, and thus prevention is more desirable than simple restitution.

In the ERO, the Ontario government states the reason is to “improve Conservation Authorities” and states that “These proposed improvements to the conservation authority system would reduce duplicative administrative costs, free-up resources for frontline conservation, and better align conservation authorities’ services with provincial priorities on housing, the economy, infrastructure and climate resilience.”

I will first address “reduce duplicative administrative costs”. In which way? Nowhere in any statement by the government are clearly defined costs, funding, or finances of any kind announced (which is not very transparent). In this new framework how much will the Government of Ontario be paying and for how long? Where are these duplicate administrative costs? Additionally, what will the cost for permitting be? Will it be averaged out? What about other costs? What will happen to the reserves?

This change will generate substantial transition costs — including human-resources integration, governance restructuring, IT migration and policy harmonization — that would divert resources from front-line service delivery and delay measurable outcomes, contrary to the Province’s own business-planning principles of value for money, cost containment and service continuity.

These boundary changes will create a geographically vast and administratively complex entity, joining south western rural and urban municipalities throughout the province with little shared watershed connection or economic alignment. The additional costs associated with this will be much higher than current ones.

Next, to address the statement “Free-up resources for frontline conservation”. Again, this reads as a line developed by someone who has never worked at a Conservation Authority, and was using the catch-all phrase from Covid-19. All members of CAs, especially the small CAs, work the frontline, including the General Manager. What is the definition of “frontline conservation”?

I would also like to remind the Minister and the Government of Ontario that in December 2021, changes in the Conservation Authorities Act resulted in the introduction of Mandatory Programs and Services which are to be delivered by all Conservation Authorities. Ontario Regulation 686/21 lists these mandatory services as: Flood Forecasting and Warning, Drought or low water response, Ice Management, water control and erosion control infrastructure, ground water sampling, permitting, and source water protection. I would remind the Minister that only programs and fees associated with these mandatory programs could use municipal levy. Are these the “frontline” services you mention?

I also believe this wording to be disingenuous at best, as what the public would view as frontline conservation differs from what is meant by this, and I believe you are utilizing that to manipulate less knowledgeable people. The public would view “frontline” as tree planting, wetland development, habitat development, erosion control, parks and conservation areas, all of which are not included in Mandatory Programs and Services.

Next, I would like to address the below inaccurate statement made in the ERO by the Provincial government:

“the regional conservation authorities would operate with greater consistency and transparency, deliver faster services to municipalities and permit applicants, while ensuring decisions continue to be based on sound science.”

To address the first issue, Transparency:
Currently, the Conservation Authorities operate with great transparency.
All permitting requirements are posted as separate required policies (as dictated by the Province) and Section 28 is posted on all CA websites.
All Conservation Authorities are audited annually, have their audited financial statements posted, have budget meetings with the municipal Board members, have quarterly financial statements brought to Board meetings, and are clear about which special levy projects are going forward.
Conservation Authority budgets are decided by and voted on by the Board of Directors which are elected municipal councillors and mayors.
All Conservation Authorities also clearly post their fees for any service they provide.
Conservation Authorities are also subject to Freedom of Information requests.

All of this speaks to the great transparency in which Conservation Authorities work.

On the flip side, the Ontario Government is not operating with transparency. I would request that the Province provide full transparency regarding the projected costs of establishing the OPCA and consolidating conservation authorities, including the impact on municipal levies and ratepayers. Additionally, full transparency on how many staff will be at the OPCA, how many staff will be fired if consolidation continues, how many board members on the OPCA and each regional Board, how is all of this decided, will these jobs be posted, and what the salary of these positions will be.

In addition, the Province already possesses the authority to establish overarching legislation, regulations, and standards through the Conservation Authorities Act and the Ministry of the Environment, Conservation and Parks. The decision to consolidate and create the OPCA is mired in secrecies and is not clear at all.

To address the second issue, Permitting.

If the Province is not happy with the timelines of permits, my recommendation would be to update the policy requirements through the Conservation Authorities Act as was done before.

Under the Conservation Authorities Act, O. Reg 40/24, Section 7 (2) it states “Upon receipt of the information required under subsection (1) and payment by the applicant of the fee charged by the authority under subsection 21.2 (4) of the Act, the authority shall notify the applicant in writing, within 21 days, whether or not the application complies with subsection 28.1 (3) of the Act and is deemed to be a complete application.”

Under Section 8 (1A) it states “An applicant may request a review by the authority if the applicant has not received a notice from the authority within 21 days in accordance with subsection 7 (2);”.

These are clear timeline rules set by the Province, that all Conservation Authorities follow and have passed individual policies to follow and maintain. The idea that it is Conservation Authorities holding up development is incorrect, as the Conservation Authorities follow all guidelines dictated by the Province. The Province set the guidelines for what must be included in a permit to be deemed complete, and the province set the response times as well. An applicant is also given an avenue to have the request reviewed by the Minister. Based on Conservation Ontario’s statistics for all the Conservation Authorities 96% of all complete permits are completed in the outlined timelines.

All of this raises one main question, what could be the reason the Ontario Government has chosen to go this route? To amalgamate the Conservation Authorities and to move and consolidate all decision-making power to Toronto? There are only two logical answers to this, and neither are good for the people of Ontario, but great for lining the pockets of Premier Doug Ford’s friends.
In doing this, the government can further undermine the Conservation Authorities’ power for permitting, and allow for more unsafe development in flood zones and ecologically important wetlands.
This is a land grab and the Ontario Government is going to sell off Conservation Authority land to developers. In 2024, Ontario Regulation 686/21 came into effect and Section 10 of the regulation required all Conservation Authorities to prepare a plan for all lands owned or controlled by the Conservation Authorities. The government was given the list of all lands owned by all Conservation Authorities. What could be the reason to want a full list of these lands?

Finally, to answer the leading questions set out in the ERO

What opportunities or benefits may come from a regional conservation authority framework?

None. Opportunities will be lost and this will have no benefits to local communities. This plan will whittle away at green-space that Conservation Authorities offer and will only benefit developers. Decisions about lands and resources should stay close to the communities that use and care for them.

Do you have suggestions for how governance could be structured at the regional conservation authority level, including suggestions around board size, make-up and the municipal representative appointment process?

The current framework of Conservation Authorities is a good governance structure.

The Province has not demonstrated that it can centralize these responsibilities effectively. Recent decisions with the Health and School Boards along with the Ontario Skills Development Fund raise concerns about fiscal responsibility, transparency, and governance, including misuse of public funds, controversial private dealings, and costly highway projects that studies show provide minimal benefit while imposing financial and environmental costs. These examples undermine confidence that centralized environmental decisions would serve the public interest.

Do you have suggestions on how to maintain a transparent and consultative budgeting process across member municipalities within a regional conservation authority?

Actually including Municipal partners, and local groups would be a start, but the Government has decided to not include them in the decisions, this is harmful and not transparent at all. Additionally, the government is currently pushing this through incredibly fast without giving any answers as to structure, decisions, finances, job-security or anything else. It will be near impossible to consult with 81 municipalities, as is the size of the proposed Lake Erie Regional CA. A regional funding model must be fair to rural municipalities and avoid cost shifts that disadvantage small communities, in Lake Erie Regional CA, that will be near impossible.

How can regional conservation authorities maintain and strengthen relationships with local communities and stakeholder?

The current 36 regional Conservation Authorities have decades long, good relationships with local communities and stakeholders. To maintain these relationships, I would keep the boundaries as is. These new boundaries are geographically vast and will be administratively complex, joining south western rural and urban municipalities throughout the province with little shared watershed connection or economic alignment will seriously harm the local communities and stakeholders.

Ontario should be strengthening locally accountable environmental protection, not dismantling it.

I urge the Province to withdraw this proposal and work collaboratively with municipalities and Conservation Authorities under the current framework. Decisions about land, water, and public safety must remain locally informed, transparent, and accountable to the taxpayers who fund them and live with their outcomes.